Wednesday, September 2, 2020

Negative Effects of Tv on Family Life Essays

Negative Effects of Tv on Family Life Essays Negative Effects of Tv on Family Life Essay Negative Effects of Tv on Family Life Essay Negative Effects of TV The TV effectsly affects family life and the individual, causing family bonds to unwind and the person to get credulous of their environmental factors. The TV keeps one snared for quite a long time, making family connections lessen and individual connections to debilitate. Not exclusively does the TV appear to be a decent option in contrast to discussions and communications among each other, yet it additionally assists with making a hole between the anecdotal universe of TV and reality. Since the creation of the home TV, it has become a urgent part in ordinary family unit life. Kids invest less energy with family, since it is essentially simpler to plunk down and be engaged by the TV. †The time spent close to it [the TV] surpasses the measure of time went through along with some other relative. † (Wattermann) Watching TV majorly affects the manner in which a kid speaks with other relatives and companions, separating them from certifiable circumstances and issues. Guardians spend extended periods working and need a powerful suppressant for their kids. Contemporary guardians work a ton, however when they return home they are not anxious to invest energy with their child†¦Ã¢â‚¬  (Wattermann) Even grown-ups fall into the fascination of removing themselves from their childs’ life, so as to unwind or pick up the available time they long want. The impact the TV has on the family has been negative in contrast with the first goal of carrying the TV i nto the home, harking back to the 1940s. The portrayal of the family staring at the TV together has changed, and now with duplicate TVs present in a home, the division and disfunction of the family has expanded. Television additionally negatively affects the individual, since it detracts from expected connections and furthermore advances awful conduct and animosities as observed on brutal TV programs. What is being viewed on TV can possibly affecting negative conduct, inside the youngster or even grown-up. In an article from the AAP or the American Association of Pediatrics, it was noticed that, â€Å"Extensive examination proof shows that media brutality can add to forceful conduct, desensitization to viciousness, bad dreams, and dread of being hurt. † (Pediatrics Vol. 108 No. ) The viciousness seen on TV, can prompt brutal acts later on. People are influenced by what they see on TV and can be impacted by the intriguing nature that is portrayed in pretty much every TV program. â€Å"Even in G-evaluated, energized motion pictures and DVDs, savagery is common† (Boyse, RN). The TV viciousness affects individuals and offspring all things considered, and despite the fact that a few projects are instructive and valuable for the turn of events and development of the youngster, there are such huge numbers of different projects going on while negate the possibility of â€Å"good TV†. TV observing additionally majorly affects the mental self portrait one has of themself. The TV paints a bogus picture of what the typical and acknowledged individual should resemble. The individual watching, thusly gets sucked into the attitude that they must resemble the very much conditioned models seen on television, this makes a wide range of issues. Weaknesses inside the individual thrive and they are continually shelled with pictures of how they ought to be, so as to fit into today’s society. While watching consistent pictures of sound ladies and men makes a few people promptly bounce off the love seat and start their â€Å"cardio routine† some kick back and envy what they just will never have. Unexpectedly, this prompts dietary issues and weight. â€Å"People, who go through a really long time before the TV sets, are under exceptionally high danger of getting overweight and large. † (API Heathline) Either way, bogus commercial of the manner in which somebody ought to be seen negatively affects the watcher. All in all, the substance on TV impacts who were are and who we need to get so as to fit into society. Another calculate included TV viewing, is the sum and the industriousness of plugs. Plugs make up a dominant part of TV broadcast appointment, attempting to impact individuals to invest energy and assets on items and new innovations that will improve you fit into society. For instance, food advertisements are continually impacting individuals to make new plans or to go to the freshest most delightful café around. Different plugs, for example, the shopping channel become speaking to the more established crowd who are separated from everyone else and continually longing for new things. This prompts swarming and different scatters, including the enslavement of TV viewing in itself. Plugs and news stories likewise convince individuals regarding legislative issues, financial issues, and social impacts in this way drafting the single direction nature of the watchers. On the off chance that individuals continually go to the TV for current reports on news and other recent developments then it stops the need to speak with each other and make the social connections expected to have a strong equalization throughout everyday life. Another difficult that emerges with TV is the impact it has on one mentally. Children spend numerous hours before the TV, particularly over extensive stretches of separation. A few grown-ups can contend that the consistent atching of TV is the start of another time of compulsion. â€Å"Studies about contrary impacts of TV fixation show the TV addicts’ individuals through its sedating desensitizing effect, making them unwind, become tired, and afterward want to observe more TV. † (Parenting-Healthy-Children) Watching TV appears to have similar impacts that propensity framing opiates have on the person. When watching a long time of TV, one is immediately loose and placed into a condition of carelessness to the outside world, in this way having comparative impacts of psyche changing medications. Television viewing effectsly affects the watcher and can prompt numerous social and individual issues. Family connections, singular hesitance, and fierce/unseemly topic all lead to the end that a lot of TV can be hurtful to our general public. Television is promptly accessible to all everything being equal, and most of the material is intended for a progressively full grown crowd. After some time, TV has changed drastically from for the most part family-situated TV projects to programs equipped to various age gatherings, so as to pull in various crowds. Youngsters and TV: The Negative Effects of Television.  Children and TV: The Negative Effects of Television. N. p. , n. d. Web. 13 Feb. 2013. Media Violence.  Media Violence. N. p. , n. d. Web. 13 Feb. 2013. Awful Effects Of Watching Too Much TV | Academic Programs International a Health Line. Scholastic Programs International Health Line Bad Effects Of Watching Too Much TV Comments. N. p. , n. d. Web. 13 Feb. 2013. The Negative E ffects of Television Addiction and Computer Addiction.  The Negative Effects of TelevisionAddiction and Computer Addiction. N. p. , n. d. Web. 13 Feb. 2013.

Saturday, August 22, 2020

Justice Is Under Threat in the Risk Society’, Is Barbara Hudson Right to Argue This?

‘Justice is under danger in the hazard society’, is Barbara Hudson option to contend this? In the UK the state informed what it expects with respect to us and in light of this gives us laws that we are not genuine to rebel. We as of now live in a true and by law state where nobody else can participate in savagery separated from the state when required, and the laws are viewed as just. From the seventeenth century to the late twentieth century there has been an adjustment in the public arena making a pioneer period which saw the closure of feudalism and the devotement of free enterprise. Hudson, 2003:3) This period saw changes in the manner in which people experienced their lives and saw the world; there were political changes and frameworks of discipline. The progressions blended ‘political, good and legitimate way of thinking †the fields at whose crossing point we discover equity. ’(Hudson, 2003:3) This exposition will feature the reasons why Barbara H udson is on the right track to contend that equity is under danger in the hazard society. It will initially diagram Kant’s and Rawls’s hypothesis of equity and it will at that point see what chance society is.Finally it will analyze if equity and the hazard society are perfect utilizing DSPD as a contextual investigation. Immanuel Kant was an illumination savant in utilitarian radicalism. He had numerous speculations what equity is and what this implies and hypotheses on how this influenced discipline. He utilized the devolvement of edification to look for the proportion of equity, whereby people are viewed as judicious and equipped for investigation and dynamic. (Hudson, 2003:5) Previously issues for equity for liberal popular governments had been about the appropriation of material and social merchandise. Hudson, 2003:6) However, for Kant his hypothesis of equity spun around the possibility of individual opportunity and equivalent opportunity for all. He accepts as w e are on the whole normal and fit for settling on are own choices that we would all be able to submit to the ethical law. Kant’s moral way of thinking depends on what he calls the downright goal, where he says ‘Always act so that you can likewise will that the proverb of your activity should turn into a widespread law’ (Kant, 1987:2) Meaning that you should regard individuals as you would need to be dealt with, and not to a conclusion to a methods, on the off chance that we don't regard individuals as equivalent, at that point there is no justice.Rawls was a contemporary radical who was an understudy of Kant’s who looked to an option in contrast to utilitarianism in his hypothesis of equity. (Kymlicka, 2002:53) His methodology was intuitionism hypothesis which he said had two highlights, that they comprise of majority of first standards and that they incorporate no unequivocal techniques and we are essentially to find some kind of harmony by instinct to wh at appears to be correct. (Kymlicka, 2002:54) Rawls had two standards of equity; the first was that ‘each individual is to have an equivalent right to the most broad plan of equivalent fundamental freedoms perfect with a comparable plan of freedoms for other people. (Kymlicka, 2002:56) He states when settling on choices we should intellectually put ourselves behind a cover of numbness for all citizenry to concur, as this would lead everybody in the public arena to be dealt with all the more decently as they would not know where in the public eye they would be set hence constraining their hazard. Along these lines you could convey merchandise totally reasonable without victimizing anybody and by doing so you would wind up with a framework where you would ensure the most noticeably awful off are also of as conceivable as we would not realize which bunch we would have been in; the rich or the poor gathering of society. Baggini, 2005:29) Rawl’s second standard of equity are that social and financial imbalances are to be orchestrated so that , they are to be the best advantage to the least advantaged individuals from the general public and workplaces and positions must be available to everybody under states of reasonable uniformity of chance. In this way since there will be consistently disparities, citizenry would consent to participate as again they would not realize which gathering of society they fall into and by evacuating all imbalances to which hindrance somebody along these lines making an all the more only society.Thus for Rawl’s, equity rises to reasonableness and decency approaches proportionality. Hazard Society hypothesis was created to guarantee why and how society is evolving. Becks and Glidden’s battled they have been changes in how society functions and recommend that we are presently living in a general public of hazard. Hazard society isn't proposing that we live in a world with more hazard however that our view of haza rd has become a key factor in our sorting out guideline. Refered to in Hudson, Ericson and Carriere state ‘We now live in a hazard society; there is a float in the open plan away from monetary imbalance to the circulation and control of dangers. (Hudson, 2003:43)There are seven key ideas to the hazard society; Modernity, Late Modernity, Reflexive modernisation, Manufactured vulnerability, Actuarialism, Risk circulation and Individualism. Late Modernity is the term utilized in the contemporary period demonstrating the changes in social orders whereby there has been move towards entrepreneur economies and globalization as opposed to government assistance approach. With late innovation you can glance back at what had been done and utilize this to assist you with foreseeing how to change later on to constrain your hazard. Denny, 2005:28) Reflexive modernisation and made vulnerability was an idea created by Becks and Giddens who are key hazard society scholars. They clarify that wi th improvement of innovation, this has made new and distinctive hazard and the innovation we have makes us increasingly mindful of the potential hazard, as the media is not, at this point just as papers and TV, we approach on PCs and even cell phones consequently we can see and hear potential dangers 24 hours per day. Adam et al, 2000:168) However, in light of the fact that we have made this hazard with the devolvement of innovation then we can comprehend it better and expect we can gauge them. They apply the idea of Actualarism that order populaces as indicated by hazard, with this idea we can quantify the hazard and the probability of them occurring and by doing this we can make strides in diminishing and evading these dangers. A basic idea in the hazard society is that to stay away from chance we can appropriate the hazard which is a piece of neo-liberalism.This can be believed to be utilized in regular day to day existence with vehicle insurance agencies who charge an individual more cash in as per the hazard they present while driving . Hazard has become an on a very basic level product in an industrialist society. Hazard society implies that hazard thinking has become standardized for people in regular day to day existence, each choice we make we consider the hazard associated with it. The ascent of independence has seen that people will buy the best hazard assurance they can without contemplating the more fragile individual in society.Hudson states that we presently dread wrongdoing from each other and due to this we need individuals who undermine us to be expelled from our condition to wipe out the hazard, this has been a contributing element to why society has gotten progressively reformatory. (Hudson, 2003:45) In the hazard society administration is aimed at the arrangement of security and experience of security normally lays on a parity of trust and adequate hazard as assurances and consistency. These dangers become externalized contrary pictures of utopias where individuals are not, at this point worried about acquiring the great yet rather, forestalling the worst.A key inquiry for liberal scholars is how much freedom ought to be exchanged for the degree of security. In today’s society the state controls and administers the manner by which we live our lives. Society has given over the ability to the state through an implicit understanding whereby we surrender a portion of our freedom in the expectation the administration can shield us from potential dangers. One of the impacts of this is we let the administration control how they rebuff offenders.Bentham and Kant, two unitlitarists held various perspectives on Punishment, For Bentham he said it is naturally awful, Bentham, a ulitarian and scholar for discipline expressed, refered to in Ashworth ‘that moral activities are those that produce the best joy of the best number of individuals. ’(Ashworth, 2010:79) ‘Therefore to legitimize discipline we shou ld do as such by demonstrating its utility. Anyway Kant felt that discipline was acceptable and there was an obligation that the guilty party got their appropriate reward through his guideline of equity. (Duff and Garland, 1994; 141) The explanation behind rebuffing must fill in as a support for that punishment.The just sweet model implies that you ought to get the discipline you merit by accepting a sentence that it is proportionate to the offense you have submitted. (Scott, 2008, 199) Indeterminate condemning which is related with utilitarianism is connected to the hazard society and equity, as on the grounds that they accept we can gauge chance they figure we can make forecasts for future violations. In any case, by rebuffing somebody for a wrongdoing they have done this thusly will help diminish wrongdoing in the conviction that dread will prevent others from perpetrating a similar wrongdoing. Honderich, 2006:26-27) However, it is shameless and there is no equity to give somebod y a harsher sentence and cause a case of them in the expectation of serving to hinder others from a similar wrongdoing. Hirsch’s study found that harsher sentences don't dissuade others and lessen crime percentage. (Hirsch, 1999:3) Indeterminate sentences violate the explanation and defense for discipline, by conceding blame for the underlying offense they expect they are liable of reoffending in this way are given longer jail sentences to benefit society this can't be just..A issue for equity while rebuffing a wrongdoer is the need to address equity for whom; the guilty party or casualty, what establishes equity for the casualty won't mean equity for the wrongdoer there will consistently be an issue adjusting the two. Ris

To Be a White Woman free essay sample

An individual paper on the encounters with race, sexual orientation, religion, and social class growing up as a white female in the South. This paper is one womans individual record of her encounters with race, religion and the social class structure of American culture. She gives a gander at these issues through her adolescence, school years and marriage and analyzes how these impacts have molded her character and conviction framework. I am a southern lady, completely. I was brought up in Tennessee, Kentucky, and Florida in a working class family. Race and sex were imperative to those in my family, particularly the more seasoned ages. My encounters with race were not quite the same as those of my more established kin, cousins, guardians, grandparents, aunties and uncles. They all had gone to isolated schools and experienced their adolescence nearly as a different animal types isolated from the blacks. My school years were spent in isolated schools, some at any rate 90% dark. We will compose a custom article test on To Be a White Woman or then again any comparable theme explicitly for you Don't WasteYour Time Recruit WRITER Just 13.90/page Much like Dalton Conley communicates in his book Honky, I realize all to well what its like to be the minority. This experience separates me to some degree from my family. Our childhoods were so unique as for friends and social exercises. I relate more to the more youthful age in the family, the nieces and nephews. As the most youthful kin of nine, I am in reality nearer in age to my siblings and sisters kids than I am to them. This has frequently been a gift however it has likewise made a separation between my kin and myself that I assume may never totally vanish.

Friday, August 21, 2020

The Best Way to Write a Research Paper Fast in 7 Simple Steps

So you have procrastinated composing your APA inquire about paper and are considering how to compose a 10-page look into paper quick. Such a circumstance isn't extraordinary for school and graduate understudies. From the outset, you meant well toward the start of the semester to give yourself sufficient opportunity to finish your unpredictable ventures. However, presently you understand that your extensive scholarly paper is expected tomorrow or in a few days and you havent even began at this point. Numerous understudies hold up till the most recent day or even night to begin an article and afterward something may turn out badly at last and they get a less than stellar score. Be that as it may, imagine a scenario in which we reveal to you that you can truly excel on your very late article. There are sure best tips and deceives for composing research papers and research papers rapidly. On the off chance that you ace them, you can turn into an overly effective understudy. In this article, well separate simple strides to composing an exploration paper all the way. On the off chance that you are searching for counsel on the most proficient method to do an exploration paper quick, continue perusing. Obviously, you may build up your own particular advances or techniques as you develop as an author so these means are simply to enable you to start. Step by step instructions to Write a Research Paper: 3 Pre-Writing Tips To start with, you have to peruse the task and comprehend the rules for your undertaking. You need to get an away from of to what extent your paper ought to be (number of words, pages) and what reference style (APA, MLA or other) is favored by your educator. At that point, you need to plan your paper and choose what measure of time you can bear to dedicate to chipping away at your scholastic paper regardless of whether it is the latest possible time. Stage 1: Pick a Topic That Is Researched a Little Bit Here and there, examine paper points are doled out to understudies yet the best situation is the point at which you are permitted to pick your theme. For this situation, you can utilize conceptualizing or mind-mapping procedures to concoct a decent subject that is applicable to your task rules and that youre keen on expounding on. The way to progress is to pick a point that is as wide as could be expected under the circumstances. Recollect that your time is restricted and you cannot bear to invest a great deal of energy doing examination to discover enough material for composing on an abnormal or an uncommon theme. Its the most ideal approach to choose a subject that a great deal of past research has been done on it. Stage 2: Do In-Depth Research Taking Quick Notes On the off chance that you don't know how to compose a 3-page investigate paper quick, remember that the quickest path is to do your examination first and build up your theory explanation later. Building up your postulation early is anything but a smart thought since you may find that there isn't sufficient proof to help it. You can begin with Wikipedia to get an expansive diagram of the theme. Other great data sources are Google Scholar, online databases and reference books, government reports and different productions, academic articles in logical diaries, papers, and so forth. You have to audit all the sources you find, assess the gathered data, and take fast notes of the key thoughts you might need to refer to or reword in your examination paper. Dont neglect to monitor your sources with the goal that you can refer to them in your paper to stay away from written falsification. You can utilize your notes later when constructing your book reference page. Stage 3: Create an Outline of Your Essay in Advance Presently when you finish your exploration and have huge amounts of thoughts, it is crucial to structure them. Before you begin composing, you have to sort out your thoughts in a blueprint. Arranging and laying out are basic for the achievement of your composing task since they will spare youre a great deal of time when you really begin composing. Without a blueprint, your venture will need center and you may invest significantly more energy during the creative cycle attempting to make sense of how to comprehend your chaotic considerations. So you ought to put some time into composing your proposition articulation and making an all around organized layout. Your proposal articulation is the fundamental thought of your paper so it should be explicit. Moreover, your proposition ought to be brief and basic. It ought to quickly layout the focuses you are going to contend in your exploration paper and bolster it with applicable proof. A framework can serve you like a guide for composing your examination paper. So attempt to make it as itemized as could be expected under the circumstances. Along these lines, you will have a smart thought of what your paper will resemble. Consider the central matters that will bolster your postulation they will be your subheadings. At that point you have to amass your notes and match all the data that fits together under every one of your sub-headings. On the off chance that any data doesnt bolster your proposition proclamation, it doesnt have a place with your scholarly paper regardless of how intriguing it is. The Fastest Way to Write a Research Paper Drafting Presently youve come up to the moment that you can really begin composing your first draft. Attempt to compose with your own voice and remember for content references where it is important to help your examination thoughts. Stage 4: Write the Abstract and Introduction First Compose a theoretical that outlines the fundamental thoughts and the motivation behind your exploration paper. At that point begin composing your presentation. The presentation should put the subject of your examination paper in a type of setting. Start with a solid opening sentence that will catch your perusers eye. At that point you ought to give some foundation data pertinent to your subject and quickly clarify why this theme is significant. You ought to likewise clarify how you are going to move toward your theme. End your presentation with your theory explanation. Stage 5: Write the Body Next Utilize your blueprint when composing your body sections and remain concentrated on your proposal proclamation. Start each body passage with a subject sentence, examine why this sentence is valid, and bolster your theme sentence with important realities and models. You can likewise utilize cites from dependable sources to help your own thoughts however you ought to disclose how they identify with your focuses. Its imperative to utilize cites sparingly and not supplant your own thoughts with them. Stage 6: Create a Logical Conclusion At the point when you complete an investigation in the composed structure, compose the end. You can rehash your theory utilizing different words and quickly sum up your paper. You should abstain from utilizing monotonous expressions and realities and thoughts that you have just expressed. You can likewise clarify why you think your focuses bolster your proposition proclamation. Plus, you can propose some fascinating thoughts and focuses for additional exploration and clarify why you think they are significant. Instructions to Finish a Research Paper Fast At the point when you compose the main draft, you ought to do fast altering and changing to improve the substance and the structure. Also, you have to edit your work. Stage 7: Revise and Edit You need to rehash your scholastic paper and ensure that it is on the point. It will require some investment as fixing your sentence structure and spelling botches. You should check the rationale and the progression of your bit of composing and make upgrades to guarantee that your paper is efficient and that there are sensible advances between your sections. You may need to dispose of redundant sentences, filler words and expresses and improve the word decision to make your paper understood and succinct. It will be simpler to get any language structure issues in the event that you read your exploration paper resoundingly. At last, you have to check spelling, language structure, and accentuation and fix all the mix-ups and grammatical mistakes if there are any. From that point forward, you should peruse your paper out loud again as though you are introducing it to your crowd to get whatever other blunders that you may have missed. Consider the title for your bit of composing and make a cover sheet if important. Presently you realize how to compose a 5-page inquire about paper quick. This is the least demanding and the quickest method to adapt to an article or research paper and it truly works (checked and demonstrated by and by most!). Obviously, composing a scholarly paper along these lines can be unpleasant so you should attempt to design your time better next time and begin writing ahead of time. At that point youll have sufficient opportunity to compose your paper in pieces and make a decent intelligent contention dependent on careful research and composed with meticulousness. We trust that these tips on the best way to compose a very late research paper quick will assist you with investing less energy finishing your difficult scholastic papers and get high evaluations. Good karma!

Rape and Associated Criminological Theories Research Paper

Assault and Associated Criminological Theories - Research Paper Example The creators think about the distinctions and similitudes between the two investigations, and social topics that were predictable over the examinations. The investigations were both embraced by the creators and utilized data present in databases held by the police and the courts. At long last, they look at what job conduct investigation of assault gives and how the social profile found in the examination varies from that which is depicted from individuals from the network who have encountered assault firsthand. The primary investigation they analyzed utilized information assembled from the police records of the Victoria Police on culprits of rape on grown-up ladies. Altogether, data was accumulated on 130 men who were accused of the wrongdoing. These records incorporate the reactions to a 263 inquiry study which is utilized to follow brutal wrongdoings in Australia. The investigation utilized the reactions from 28 of these inquiries which concentrated on the conduct attributes of att ackers. The entirety of the men whose data had been utilized had been charged inside the past a year. The second examination that the creators analyzed utilized transcripts from legal disputes that had happened inside the previous five years. An aggregate of 50 transcripts were utilized, and these spoke to men blamed for rape of a grown-up lady. ... Five social topics were analyzed all through the two investigations, and the pervasiveness of these in every one of the cases was inspected. The subjects were: merciless or physical, oral, vaginal, kissing or petting and butt-centric. These were controlled by assessment of the inquiries utilized in the overview for the main examination and what the normal subjects were. The creators found that the most well-known connection between assault casualties and the culprits of the assault was that of outsiders for the two examinations they inspected. For the two examinations the creators found that the most widely recognized subject was vaginal, and most basic blend of topics was kissing and vaginal. Dirt Warner and McMahon-Howard tried two hypotheses of whether, and assuming this is the case, how and when assault casualties report being assaulted utilizing information assembled related to the Census Bureau known as the National Crime Victimization Survey (NCVS). The NCVS is an overview tha t is together directed by the Census Bureau and the Bureau of Justice Statistics. The test configuration is utilizes defined groups, with people living on army installations, restorative offices and without a home prohibited from the study. When chosen for the study, a family will stay inside it for a long time, with interviews led at regular intervals on every person over the age of 12. Reactions to the study were broke down for people who announced sexual infringement, this was the dependant variable. For the primary investigation the reactions were ordered into revealed and not detailed. In the subsequent examination, the outcomes were separated into three classes, announced by the person in question, not revealed and detailed by an outsider. The two hypotheses that Clay-Warner and McMahon-Howard inspected are the Behavior of Law hypothesis, proposed by Black and Classic Rape Theory. The

Sunday, June 28, 2020

How Much Student Loan Debt is Too Much

HomeFinanceFinancial aidHow Much Student Loan Debt is Too Much?This page may contain affiliate links.Nov 26, 2019 If you have a student planning for college, you are probably aware of the current student loan crisis and the ramifications of student loan debt. In the past, many families have allowed their student to attend a college that is financially out of reach by subsidizing the cost with federal student loans, private loans, and parent loans. But parents and students should be concerned when applying to college and determining the cost. Financial experts and college planning experts agree the ability to pay for college should be a part of the final decision. But do the costs outweigh the benefits? Student Loan Debt Statistics First, let’s look at the statistics. According to data from theU.S. Federal Reserve, Americans are more burdened by student loan debt than by credit card debt. There are 45 million borrowers who owe over $1.56 trillion in student loan debt. That’s about $521 billion more than the total U.S. credit card debt. Data from the class of 2018 shows 69% of college students took out student loans, both private and federal, graduating with an average debt of $29,800. Parents took out an average of $35,600 in federal Parent PLUS loans to pay for their student’s education. The average monthly student loan payment (among those not in deferment) is $393. The median monthly student loan payment (among those not in deferment) is $222. Imagine graduating with a low-paying entry-level job and being burdened with college debt that you are unable to repay. Why Would I Take Out a Student Loan? It’s simple—college is expensive. Without student loans, many families would be unable to afford college. Student loans were meant to help families decrease the personal financial burden of paying for college while allowing the student to repay them after graduation after obtaining employment . Unfortunately, many students borrow too much and aren’t prepared for the strain it puts on an entry-level salary. Student loans aren’t â€Å"bad†, particularly if borrowed wisely and used to supplement other college funds such as family savings, scholarships, merit aid, and wages earned while working during college. The key is to borrow only what you need and understand your repayment responsibilities. How Much Debt is Unreasonable? In a Washington Post article about college costs and college debt, a few experts weighed in on how much debt is unreasonable. Several agreed that the rule of thumb for total undergraduate borrowing should be limited to what you might expect to make in your first year after graduation. Mark Kantrowitz, an expert on student financial aid and student loans explained, â€Å"If total debt is less than annual income, you should be able to repay your student loans in 10 years or less.† Sara Goldrick-Rab, author of Paying the Price: College Costs, Financial Aid, and the Betrayal of the American Dream and a professor at Temple University, had additional advice. â€Å"Debt in an amount that causes the students or the family stress — whether before, during, or after college — is too much debt.† Andrew B. Palumbo, dean of admissions and financial aid at Worcester Polytechnic Institute, said how muchto borrow for college â€Å"is an inherently personal decision that is best made after conducting thoughtful research. Students and their parents should know their school’s graduation rate, loan default rate, and the likely return on investment for the major they choose.† In addition, the amount of debt your student takes on during college should be thoroughly discussed and analyzed before signing on the dotted line. Many college financial aid offices provide loan documents without proper financial counseling. You and your student must understand the responsibilities and the consequences of borrowing to pay for college How Do You Determine Your College ROI (Return on Investment)? It’s important to calculate the ROI of your student loans. For example, borrowing $200,000 to pay for a degree that promises a starting salary of $40,000 per year would be a poor return on investment. This would be considered high debt for student loans. As stated earlier, to make things simple, your amount of student loans should be less than your first year post-graduation salary. But how do you know what your potential salary might be? TheBureau of Labor Statistics Occupational Outlook Handbookis a great online resource to use. You can look up any career along with statistics related to its growth potential and projected need, and find the average starting salary for whatever degree your student is pursuing. If your student is still undecided, look up the salary for a bachelor’s degree recipient. That should give you a good figure to use when calculating your student’s loan/debt manageability. You should also consider other debt and maintain a manageable debt-to-income ratio . The student loan payment should be limited to 8-10 percent of the gross monthly income. For example, for an average starting salary of $30,000 per year, with expected monthly income of $2,500, the monthly student loan payment using 8 percent should be no more than $200. Allocating more than 20 percent of discretionary income toward student loans can overburden your student and make it impossible to repay their loans in a timely manner. How Do You Calculate Student Loan Payments? In order to calculate your student loan payments, you must first determine how much your student will be borrowing for college along with the interest rates. All students qualify for federal student loans, and you should always consider these before taking out private loans. Federal loans allow for deferment and forbearance when necessary whereas the rules for private loan repayment are stricter and the interest rates are higher. These are calculations that might fluctuate over the course of four years, but doing them will help your student stay on track and not borrow more money than they can repay. There are many loan repayment calculators available, and to help parents and students make informed decisions about student loan cost, we developed theRoad2College Student Loan Calculator. We also share how to use this simple worksheet and the key factors to consider when comparing student loans. Parents and students should have a serious discussion about college financing. With every lender, look at the interest rates, repayment terms and repayment flexibility. Pay attention to the federal loans, especially the ones that are unsubsidized, because the interest will accrue while your student is in college. With these loans, it’s wise to pay the interest if it’s affordable. What Are Some Simple Borrowing Rules to Follow? After evaluating all the statistics and looking at the student loan data, you might be overwhelmed. If so, here’s a simple checklist to follow: Do your research (look at salaries, career growth patterns, and loan repayment amounts). If necessary, investigate cheaper alternatives (community college, public universities, or work and pay as you go). Don’t borrow more than the first-year salary after graduation and consider debt-to-income ratios. Borrow only what you truly need for educational expenses. If you follow these simple rules of borrowing, you should be able to keep your student’s college debt manageable. While student loans can help families pay for college, it’s important to remember over borrowing can lead to crushing debt after graduation. Long-term debt is not only unmanageable, but will affect your student’s future borrowing potential for major purchases. Be a wise consumer. Do your homework. Look at the figures. Make wise financial choices.

Wednesday, June 3, 2020

Whiplash Claims in the UK - Free Essay Example

What, if anything, should the Government do about whiplash claims in this country? The need for our government to take action in regards to whiplash claims would depend on whether there is a problem in the first place. The problem in this respect can take on many forms, namely with either procedure, access to justice, other methods of resolving dispute (ADR[1]), policy, legislation, social dynamics and/or economical climate of the whole country. It is therefore vital to identify the problem and where it stems from, before searching for appropriate solutions. For the purposes of this essay I will be focusing on the past policy changes in regards to personal injury, such as the introduction of legal aid system and the Legal Aid Board, Lord Woolfà ¢Ã¢â€š ¬Ã¢â€ž ¢s review of the Civil Procedure Rules and Access to Justice Report[2] and Lord Jackson Reforms. I will aim to demonstrate that there are considerable claims in regards to à ¢Ã¢â€š ¬Ã…“compensation cultureà ¢Ã¢â€š ¬Ã‚ [3] and à ¢Ã¢â€š ¬Ã…“whiplash epidemic,à ¢Ã¢â€š ¬Ã‚ [4] but those assertions are largely unfounded and seem to serve as an excuse for political and economical goals. Nonetheless, the current changes are both reactive and proactive, and can be seen as necessary in our current economical climate. The problem in this case is subjective, everyone involved would take a different view depending which interests they represent and the end goal they are trying to achieve. It is difficult to determine whether there has been a major increase in RTA over the years as unfortunately there is no reliable, year by year, statistical data to prove the case either way.[5] Nonetheless, when it comes to whiplash injury, Jack Straw quoted that it is as high as 80% of all the RTAs[6] leading to Britain being branded the à ¢Ã¢â€š ¬Ã…“whiplash capital of Europe.à ¢Ã¢â€š ¬Ã‚ [7] Lord Jacksonà ¢Ã¢â€š ¬Ã¢â€ž ¢s review of PI claims found that claimants had too many benefits, making smaller claims, namely whiplash claims, an easy target for fraudsters. Unsurprisingly ABI[8] was strongly in support of the reforms that followed and APIL[9] were strongly against. What is plainly evident is that the two sides reflect the interests of their industries. Fault based liability seems to be turning into cost based liability. Lord Dyson suggests that claimants have à ¢Ã¢â€š ¬Ã…“lost all sense of personal responsibilityà ¢Ã¢â€š ¬Ã‚ [10] blaming the media for creating a false belief that litigation is a quick financial boost rather than a genuine solution to a p roblem à ¢Ã¢â€š ¬Ã…“[t]he compensation culture is a myth; but the cost of this belief is very real.à ¢Ã¢â€š ¬Ã‚ [11] Nonetheless, Dyson diverts the blame from the system à ¢Ã¢â€š ¬Ã…“compensation culture is not about what goes on in court, but rather about what happens outside the court roomà ¢Ã¢â€š ¬Ã‚ [12] and rejecting claims that UK has developed the US style litigation culture.[13] Some of the biggest changes to affect whiplash claims have been made first through the Lord Woolfà ¢Ã¢â€š ¬Ã¢â€ž ¢s review which focused on the disproportion caused by the legal aid system and just recently by Jackson Reforms, which were introduced to target the imbalance generated by the Access to Justice Act 1999 between claimants and defendants. The Jackson Reforms introduced a shift between the claimant and the defendant especially in regards to the small claims track. The new model of Conditional Fee Arrangements that abolish the recoverability of success fees and API premiums m ean that the claimant will be covering some of the costs through the awarded damages.[14] These reforms can be seen to not only continue maintaining access to justice through CFA, but also significantly reducing costs and disproportionate fees.[15] These reforms alter the traditional model of full compensation. Cane draws on Lord Denning criticism of the old model in Lim Poh Choo v. Camden Health Authority[16] à ¢Ã¢â€š ¬Ã…“it would be unfair and unreasonable to award damages for loss of earnings if the claimant was in no position to benefit from them.à ¢Ã¢â€š ¬Ã‚ [17] The new reforms do not target so much how the damages are calculated, but more how much the claimant is actually left with. The courts often find themselves in a difficult position having to calculate a value in financial terms on the injuries and possible future losses which, through their subjective judicial activism, this can result in considerably varied applications of awards. à ¢Ã¢â€š ¬Ã…“There seems no r eason why a young person should be maintained for the rest of their life by an award of damages (paid by society in one way or another) simply because their spouse or partner was killed through someoneà ¢Ã¢â€š ¬Ã¢â€ž ¢s fault. It is surely not right that the law should reward idleness and discourage gainful activity in this way.à ¢Ã¢â€š ¬Ã‚ [18] Although Cane was talking about fatal accidents, damaged in whiplash claims are often also difficult to calculate[19] and disproportionate claims[20] can arise when calculating future losses in regards to whiplash personal injury claims, sometimes depending on the length of the claimed pain not severity.[21] The claimants must take reasonable steps to mitigate their loss, but it is difficult to prove whether or not a claimant has done all that is reasonably expected of them to reduce their costs and again it is left up to the courts to decide what is reasonable. Currently a claimant can include private medical treatment[22] in their da mages even if it is available through the NHS à ¢Ã¢â€š ¬Ã…“(in more than a third of cases), in order to have an examination necessary for the claim.à ¢Ã¢â€š ¬Ã‚ [23] This seems to go strongly against the mitigation principle à ¢Ã¢â€š ¬Ã…“[i]t is not at all obvious why, sixty years after the beginning of the NHS, we should continue to subsidize those who seek private treatment in the way that the tort system does.à ¢Ã¢â€š ¬Ã‚ [24] This is something the Government can potentially address in regards to whiplash injury, as these claimants are unlikely to require treatments the NHS does not already provide. Current proposals for medical whiplash panels have been accepted by the Ministry of Justice and are likely to be implemented.[25] The Civil Justice Council has indicated the need for independent panels with an accreditation model to provide skilled advice, but indicated the need for heavy regulation à ¢Ã¢â€š ¬Ã…“are assessed and authorised on the basis of their experti se, and not organisations that can then hire or instruct individual doctors who are not then subject to any independent scrutiny or authorisation.à ¢Ã¢â€š ¬Ã‚ [26] This model looks promising and aims to be à ¢Ã¢â€š ¬Ã…“i) flexible; ii) transparent; iii) independent.à ¢Ã¢â€š ¬Ã‚ [27] Nonetheless, with whiplash injuries being so difficult to prove, medical panels, no matter how independent, are unlikely to spot fraudsters. Their reports would produce largely subjective results. Motor Investigation Unit has been researching more modern solutions through social media and technical equipment like on board CCTV.[28] In Golden v. Dempsley[29] the courts accept the MIU[30] take a different approach to evidence, with more focus on the claimantà ¢Ã¢â€š ¬Ã¢â€ž ¢s credibility. In reference to Kearsley v Klarfeld[31] and Casey v Cartwright[32] the district judge also notes the need for early access to the car for inspection and medical records, but also stresses that those should not be the main focus. The recent reforms were heavily criticised by the Law Society and APIL who are disadvantaged by the new changes, à ¢Ã¢â€š ¬Ã…“propaganda which is generated by insurers on the pretext that insurance premiums will be reduced and that this will in turn assist the countryà ¢Ã¢â€š ¬Ã¢â€ž ¢s economic recovery.à ¢Ã¢â€š ¬Ã‚ [33] Claire McIvor takes an individualistic approach arguing that the new reforms significantly reduce claimantà ¢Ã¢â€š ¬Ã¢â€ž ¢s access to justice and impede on their Human Rights, primarily Article 6 à ¢Ã¢â€š ¬Ã…“access to justice is, after all, a fundamental human rightà ¢Ã¢â€š ¬Ã‚ ¦under the terms of art.6, it is unqualified in terms of cost considerations.à ¢Ã¢â€š ¬Ã‚ [34] However, too much access to justice can create chaos, Friedman refers to this as an à ¢Ã¢â€š ¬Ã…“Orwellian nightmare,à ¢Ã¢â€š ¬Ã‚  where access to justice is so open, that anyone can claim for anything with ease, and in effect we end up regulating each other, à ƒ ¢Ã¢â€š ¬Ã…“we cannot have a system that provides unlimited access to justice; the pyramid must remain a pyramid.à ¢Ã¢â€š ¬Ã‚ [35] Individuals are likely to fight for their own interests with disregard of how it might affect someone in the future through policies, allowing the pyramid to lose its shape would likely result in a dysfunctional welfare state à ¢Ã¢â€š ¬Ã…“not justice but economical inefficiency and waste.à ¢Ã¢â€š ¬Ã‚ [36] McIvor takes a normative approach, but disregards economical efficiency completely à ¢Ã¢â€š ¬Ã…“minimum costs will consist solely of those costs which are necessary à ¢Ã¢â€š ¬Ã‚ ¦regardless of whether they can be described economically efficient.à ¢Ã¢â€š ¬Ã‚ [37] This is a good theoretical model, but one that does not work in practice, it is quite an unrealistic model considering economy is the driving force and is what allows UK to compete on an international level pedestal with other leading economies. If we disregard economy with s uch ease in every area of governance and politics then we are likely to be in constant recession. McIvor states that à ¢Ã¢â€š ¬Ã…“substantive aspect of the process should take priority over the procedural.à ¢Ã¢â€š ¬Ã‚ [38] However, Friedman argues that à ¢Ã¢â€š ¬Ã…“[c]heapness and convenience, while obviously important, are hollow and meaningless without a working system of relevant rights.à ¢Ã¢â€š ¬Ã‚ [39] A working system is one that can continue functioning, that can sustain itself. The reforms[40] represent a give and take scenario, with the abolition of success fees and ATE premiums on the one hand and the 10% increase in general damages[41], 25% cap on success fees from damages and qualified one way cost shifting on the other. It is an attempt to distribute costs between all parties, the claimants, defendants and even the claimantà ¢Ã¢â€š ¬Ã¢â€ž ¢s lawyers. Although the claimant is viewed by some as à ¢Ã¢â€š ¬Ã…“the little guy in the face of giant corporations à ¢Ã¢â€š ¬Ã‚ [42] he is also the à ¢Ã¢â€š ¬Ã…“one-time litigantà ¢Ã¢â€š ¬Ã‚ [43] so unlike the defendant, likely an insurance company, in the event the claimant loses their case they will only bear the costs once, if at all.[44] The costs do balance out between the parties that way, just because insurance companies have more assets at an individualistic level, does not mean that they should carry the cost burden so significantly, this would not work with every case. Many claimants do not realise that personal injury civil litigation is not funded through the state, legal aid has been cut significantly and now it is publicly funded, so the costs come back round on us in a vicious circle through insurance premiums. The Jackson Reforms have deep political roots. We have been experiencing difficult economical times and are just emerging from the deepest recession of 2008-2009s since the war time of the 1920s.[45] We cannot look at the recent changes in whiplash claims policy i n isolation from the economical and political climate that evoked those changes. It is possible that the à ¢Ã¢â€š ¬Ã…“compensation cultureà ¢Ã¢â€š ¬Ã‚  is an excuse, but the problem remains and that is excessive litigation in the whiplash area of civil litigation. There are very little changes that I would advise our Government to make in relation to whiplash claims in this country. I would advise an introduction of a whiplash NHS care package to speedily deal with medical reports of claimants, this is, however, likely to be introduced together with the medical panels and the accreditation scheme. Through past history of the legal aid introduction, then the Access to Justice Act 1999, and now the Jackson Reforms, what is evident is this constant emerging imbalance between the two sides, justice and morality often lies on the side of the claimant and economical prosperity on the defendantà ¢Ã¢â€š ¬Ã¢â€ž ¢s side, usually a corporation. The way this imbalance is targeted is by restricting the side that is causing an imbalance, it is something that will continue to be done. Social tendencies dictate that whichever party gets better provisions, will take advantage of it and in some cases even abuse it, such as the fraudulent whiplash claims. That is not to say the system we have at the moment is the optimal, best suited system, but it is one that seems to be reflecting the current economical conditions. The new changes introduced by way of Jackson Reforms are unlikely to stick around long enough to make a long lasting imprint in history, but it seems they are better suited for the current identified imbalance and will remain in place until the scales tip in the opposite direction. Bibliography: Lim Poh Choo v. Camden Health Authority [1980] AC 174. Motto and others v. Trafigura Ltd and another [2011] EWCA Civ 1150. Valentine v McGinty [2010] G.W.D. Langford v Hebran [2001] EWCA Civ 361. Fairley v Thomson [2004] Rep. L.R. 142. Golden v. Dempsley [2010] 9B106073. Kearsley v Klarfeld [2005] EWCA Civ 1510. Casey v Cartwright [2006] EWCA Civ 1280. Simmons v Castle [2012] EWCA Civ 1039. Access to Justice Act 1999. Legal Aid, Sentencing and Punishment of Offenders Act 2012 Law Reform (Personal Injuries) Act 1948. Conditional Fee Agreements Order 2013. C McIvor, à ¢Ã¢â€š ¬Ã‹Å"The Impact of the Jackson reforms on access to justice in personal injury litigationà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2011) CJQ. LM Friedman à ¢Ã¢â€š ¬Ã‹Å"Access to Justice: Some Historical Commentsà ¢Ã¢â€š ¬Ã¢â€ž ¢ 2009 37(1) Fordham Urb. LJ Article 4, 7 CFA covers legal fees; however additional costs such as medical reports and court fees might have to be covered by the claimant in the even they lose their case. Steve Hawkes , à ¢Ã¢â€š ¬Ã‹Å"Britainà ¢Ã¢â€š ¬Ã¢â€ž ¢s compensation culture is out of control, insurance chief warnsà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Telegraph, 4 August 2013). R. Lewis, A. Morris and K. Oliphant, à ¢Ã¢â€š ¬Ã‹Å"Tort personal injury claims statistics: is there a compensation culture in the United Kingdom?à ¢Ã¢â€š ¬Ã¢â€ž ¢ [2006] JPIL 103. Master of The Rolls Lord Dyson, Compensation Culture: Fact or Fantasy? (Holdsworth Club Lecture, 15 March 2013). P. Cane, Atiyahà ¢Ã¢â€š ¬Ã¢â€ž ¢s Accidents, Compensation and the Law (7th ed., Cambridge, 2006). Law Society, Reducing the number and costs of whiplash claims A consultation on arrangements concerning whiplash injuries in England and Wales (March 2013). Civil Justice Council, Reducing the Number Costs of Whiplash Claims. https://www.telegraph.co.uk/finance/newsbysector/banksandfinance/insurance/10221301/Britains-compensation-culture-is-out-of-control-insurance-chief-warns.html Accessed 14/03/2014 to 20/03/2014 Chinwe Akomah, à ¢Ã¢â€š ¬Ã‹Å"ABI seeks à ¢Ã¢â€š ¬Ã‹Å"radicalà ¢Ã¢â€š ¬Ã¢â€ž ¢ action to tackle whiplash epidemicà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Post Online, 27 April 2012) https://www.postonline.co.uk/post/news/2170911/ abi-outlines-radical-plans-tackle-whiplash-epidemic Accessed 14/03/2014 to 20/03/2014 à ¢Ã¢â€š ¬Ã‹Å"Jack Straw calls for reform of car insurance industryà ¢Ã¢â€š ¬Ã¢â€ž ¢ (BBC, 27 June 2011) https://www.bbc.co.uk/news/uk-13922554 Accessed 14/03/2014 to 20/03/2014 Ray Massey, à ¢Ã¢â€š ¬Ã‹Å"Europeà ¢Ã¢â€š ¬Ã¢â€ž ¢s whiplash capital: Compensation culture makes British twice as likely to claim, adding  £90 to premiumsà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Daily Mail, 20 April 2013) https://www.dailymail.co.uk/news/article-2311979/Europes-whiplash-capital-Compensation-culture-makes-British-twice-likely-claim-adding-90-premiums.html Accessed 14/03/2014 to 20/03/2014 John Hyde, à ¢Ã¢â€š ¬Ã‹Å"MoJ confirms plans for medical whiplash panelsà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Law Gazette, 16 January 2014) https://www.lawgazette.co.uk/practice/moj-confirms-plans-for-medical-whiplash-panels/5039395.article Accessed 14/03/2014 to 20/03/2014 à ¢Ã¢â€š ¬Ã‹Å"Fraud à ¢Ã¢â€š ¬Ã¢â‚¬Å" December 2011à ¢Ã¢â€š ¬Ã ¢â€ž ¢ (Weightmans, December 2011) https://www.weightmans.com/library/newsletters/fraud_-_december_2011/lvi_-_a_fresh_approach.aspx Accessed 14/03/2014 to 20/03/2014 Graham Hiscott, à ¢Ã¢â€š ¬Ã‹Å"Budget 2014: George Osborneà ¢Ã¢â€š ¬Ã¢â€ž ¢s recovery exposed as a conà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Mirror, 19 March 2014) https://www.mirror.co.uk/news/uk-news/budget-2014-george-osbornes-recovery-3258255 Accessed 19/03/2014 to 20/03/2014 [1] Alternative Dispute Resolution. [2] Resulting in new legislation, Access to Justice Act 1999. [3] Steve Hawkes , à ¢Ã¢â€š ¬Ã‹Å"Britainà ¢Ã¢â€š ¬Ã¢â€ž ¢s compensation culture is out of control, insurance chief warnsà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Telegraph, 4 August 2013) https://www.telegraph.co.uk/finance/newsbysector/banksandfinance/insurance/10221301/Britains-compensation-culture-is-out-of-control-insurance-chief-warns.html [4] Chinwe Akomah, à ¢Ã¢â€š ¬Ã‹Å"ABI seeks à ¢Ã¢â€š ¬Ã‹Å"radicalà ¢Ã¢â€š ¬Ã¢â€ž ¢ action to tackle whiplash epidemicà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Post Online, 27 April 2012) https://www.postonline.co.uk/post/news/2170911/abi-outlines-radical-plans-tackle-whiplash-epidemic [5] R. Lewis, A. Morris and K. Oliphant, à ¢Ã¢â€š ¬Ã‹Å"Tort personal injury claims statistics: is there a compensation culture in the United Kingdom?à ¢Ã¢â€š ¬Ã¢â€ž ¢ [2006] JPIL 103. [6] à ¢Ã¢â€š ¬Ã‹Å"Jack Straw calls for reform of car insurance industryà ¢Ã¢â€š ¬Ã¢â€ž ¢ (BBC, 27 J une 2011) https://www.bbc.co.uk/news/uk-13922554 [7]Ray Massey, à ¢Ã¢â€š ¬Ã‹Å"Europeà ¢Ã¢â€š ¬Ã¢â€ž ¢s whiplash capital: Compensation culture makes British twice as likely to claim, adding  £90 to premiumsà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Daily Mail, 20 April 2013) https://www.dailymail.co.uk/news/article-2311979/Europes-whiplash-capital-Compensation-culture-makes-British-twice-likely-claim-adding-90-premiums.html [8] Association of British Insurers. [9] Association of Personal Injury Lawyers. [10] Master of The Rolls Lord Dyson, Compensation Culture: Fact or Fantasy? (Holdsworth Club Lecture, 15 March 2013) 6. [11]Ibid, Lord Dyson quoting BRTF, 4. [12] Ibid 11. [13] Ibid 8. [14] Implemented through s44 and s46 of the Legal Aid, Sentencing and Punishment of Offenders Act 2012; and Conditional Fee Agreements Order 2013. [15] Motto and others v. Trafigura Ltd and another [2011] EWCA Civ 1150. [16] [1980] AC 174. [17] Ibid. [18] P. Cane, Atiyahà ¢Ã¢â€š ¬Ã¢â€ž ¢s Accidents, Compensation and the Law (7th ed., Cambridge, 2006) 155. [19] Valentine v McGinty [2010] G.W.D. [20] Langford v Hebran [2001] EWCA Civ 361. [21] Fairley v Thomson [2004] Rep. L.R. 142. [22] Law Reform (Personal Injuries) Act 1948, s. 2(4). [23] Ibid (n 17) 155. [24] Ibid (n 17) 151. [25] John Hyde, à ¢Ã¢â€š ¬Ã‹Å"MoJ confirms plans for medical whiplash panelsà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Law Gazette, 16 January 2014) https://www.lawgazette.co.uk/practice/moj-confirms-plans-for-medical-whiplash-panels/5039395.article [26] Civil Justice Council, Reducing the Number Costs of Whiplash Claims. [27] Ibid. [28] à ¢Ã¢â€š ¬Ã‹Å"Fraud à ¢Ã¢â€š ¬Ã¢â‚¬Å" December 2011à ¢Ã¢â€š ¬Ã¢â€ž ¢ (Weightmans, December 2011) https://www.weightmans.com/library/newsletters/fraud_-_december_2011/lvi_-_a_fresh_approach.aspx [29][2010] 9B106073 [30] Motor Investigation Unit. [31] [2005] EWCA Civ 1510. [32] [2006] EWCA Civ 1280. [33] Law Society, Reduci ng the number and costs of whiplash claims A consultation on arrangements concerning whiplash injuries in England and Wales (March 2013) 2. [34] C McIvor, à ¢Ã¢â€š ¬Ã‹Å"The Impact of the Jackson reforms on access to justice in personal injury litigationà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2011) CJQ. [35] LM Friedman à ¢Ã¢â€š ¬Ã‹Å"Access to Justice: Some Historical Commentsà ¢Ã¢â€š ¬Ã¢â€ž ¢ 2009 37(1) Fordham Urb. LJ Article 4, 7. [36] Ibid 9. [37] Ibid (n 30). [38] Ibid (n 30). [39] Ibid (n 31) 4. [40] Lord Jackson Reforms 2013. [41] Introduced through Simmons v Castle [2012] EWCA Civ 1039. [42] Ibid (n 31) 6. [43] Ibid (n 30). [44] CFA covers legal fees; however additional costs such as medical reports and court fees might have to be covered by the claimant in the even they lose their case. [45] Graham Hiscott, à ¢Ã¢â€š ¬Ã‹Å"Budget 2014: George Osborneà ¢Ã¢â€š ¬Ã¢â€ž ¢s recovery exposed as a conà ¢Ã¢â€š ¬Ã¢â€ž ¢ (Mirror, 19 March 2014) https://www.mirror.co .uk/news/uk-news/budget-2014-george-osbornes-recovery-3258255